Comments on Trademark Clearinghouse "Strawman Solution" and LPR

[robyn_y_ettricks@xxxxxxxxxxxx]

Sir or Madam:

        I write to you on behalf of The Vanguard Group, Inc., one of the 
largest mutual fund, financial services and investment management 
companies in the world.  Vanguard has over 22 million shareholders and 
manages $2 trillion in U.S. assets under management.  For more 
information, please visit our website at www.vanguard.com. 

        Vanguard supports the adoption of both enhanced trademark Rights 
Protection Mechanism (RPM) proposals, specifically, the Limited 
Preventative Registrations (LPR) and "Strawman Solution."  Both proposals 
are necessary to provide a minimum of protection for Internet users and 
brand owners.  However, although the Strawman Solution is a step in the 
right direction, the proposal as drafted regarding the Claims 2 process is 
insufficient.  Rather, the Trademark Clearinghouse should continue in 
perpetuity without diminishing the protection it offers. 

        Indeed, we believe the LPR is the more favorable of the two 
proposed RPMs to provide Vanguard and our shareholders and prospects 
long-term protection from false and misleading domain names and websites. 
Without the LPR, Vanguard will be forced to incur significant costs to 
defensively register second-level domain names in hundreds of new gTLDs, 
at prohibitive expense, to protect our consumers and our brand. 

        Thank you for your consideration.


Robyn Y. Ettricks, Esq.
Associate Counsel, Intellectual Property & Technology
Vanguard
100 Vanguard Blvd., V16
Malvern, PA  19355
Tel:  (610) 503-5893
Fax:  (610) 503-5737
Email:  Robyn_Ettricks@xxxxxxxxxxxx


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